Justia Connecticut Supreme Court Opinion Summaries

In this case concerning the proper recipient of heart and hypertension benefits under Conn. Gen. Stat. 7-433c for permanent disability if such benefits vested and were payable during the claimant's lifetime but were not paid to the claimant before his death the Supreme Court reversed the decision of the Compensation Review Board concluding that the executrix of the decedent's estate was improperly was substituted as party claimant, holding that heart and hypertension benefits under § 7-433c may be paid to a claimant’s estate if such unpaid benefits matured before the claimant’s death.The Workers' Compensation Commissioner granted the motion to substitute the executrix as a party claimant. The Board concluded that the executrix was improperly substituted as party claimant because a claimant's estate cannot receive the claimant's vested but unpaid section 7-433c benefits. The Supreme Court disagreed, holding (1) neither Morgan v. East Haven, 546 A.2d 243 (Conn. 1988), nor any other legal authority barred the substitution to the extent that the executrix sought payment of matured benefits; but (2) because the record did not support the determination that the decedent's section 7-433c disability benefits matured before his death, this case must be remanded for further proceedings to decide the proper beneficiary of any benefits due. View "Brennan v. Waterbury" on Justia Law

The Supreme Court held that inmates charged in criminal cases, some of whose telephone calls and noncontact visits have been recorded and reviewed by the Department of Corrections, are not entitled, under Brady v. Maryland, 373 U.S. 83, 87 (1963), to a review of all calls and visits even though the Department has limited its review to only some of the recorded conversations.While the Department automatically records all calls and visits of all inmates, when a Department, acting as an investigative arm of the State, reviews some of those calls and visits as part of the investigation into an inmate's particular criminal case, the calls and visits reviewed are subject to Brady's disclosure requirements. Defendant issued a subpoena to the Department seeking the production of more than 1500 audio recordings of calls and visits of Defendant's four codefendants. The trial court granted in part the motions to quashed filed by the State and the Department, concluding that Defendant must first make a showing that the recordings contained exculpatory information. The Appellate Court affirmed. The Supreme Court affirmed, holding that because the recordings at issue were not part of the investigation of the State's case against Defendant, Defendant was not entitled to review the recorded conversations. View "State v. McCoy" on Justia Law

The Supreme Court reversed in part the judgment of the Appellate Court affirming Defendant's conviction of one count of murder, holding that the trial court should have dismissed rather than denied Defendant's motion for a new trial.After the jury returned its verdict but prior to the sentencing date, Defendant filed a motion for a new trial. The sentencing hearing went forward, and the court sentenced Defendant. Defendant subsequently sought to have his motion for a new trial heard. The trial court denied the motion without a hearing on the ground that it had lost jurisdiction. The Appellate Court affirmed, holding that the motion was correctly denied because the trial court lost jurisdiction once Defendant's sentence was executed. The Supreme Court reversed in part and remanded with direction to dismiss Defendant's motion for a new trial, holding (1) given that the trial court lacked jurisdiction over Defendant's motion for a new trial, the court should have dismissed Defendant's motion; and (2) the trial court's failure to rule on Defendant's motion for a new trial prior to sentencing did not constitute plain error. View "State v. Guerrera" on Justia Law

In this dispute between the Board of Education of the Town of New Milford (Board) and the New Milford Education Association (Union) the Supreme Court affirmed the judgment of the trial court denying the Board's application to vacate a grievance arbitration award and granting the Union's application to confirm the grievance arbitration award, holding that the arbitrator did not manifestly disregard the law and properly concluded that the Union's grievance was arbitrable.The Union, which represented the teachers employed by the Board, filed a grievance alleging that the Board had violated an agreement between the parties. The arbitrator decided the grievance in the Union's favor. The trial court denied the Board's application to vacate the grievance arbitration award and granted the Union's application to confirm the award. The Supreme Court affirmed, holding that the trial court (1) correctly denied the Board's application to vacate the grievance arbitration award on the grounds that the arbitrator manifestly disregarded the law by concluding that the doctrines of collateral estoppel and res judicata did not apply to bar the Union's grievance; and (2) the trial court properly concluded that the Union's grievance was arbitrable under the terms of the agreement. View "Board of Education of Town of New Milford v. New Milford Education Ass'n" on Justia Law

The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for a writ of habeas corpus, holding that Petitioner established good cause for failing to raise his claim at trial or on direct appeal that he was deprived of his right to counsel.Following a jury trial, Petitioner was found guilty of sexual assault and risk of injury. Petitioner filed a petition for writ of habeas corpus, alleging that he had wrongfully been denied counsel at his criminal trial. Petitioner failed to raise a claim related to that deprivation either at trial or on direct appeal. The State filed a return asserting an affirmative defense of procedural default. The habeas court granted the petition, concluding that a claim of public defender error was not procedurally defaulted. The Appellate Court affirmed. The Supreme Court affirmed, holding that, for purposes of determining whether a habeas claim is barred by procedural default, prejudice is presumed when the petitioner is completely denied his right to counsel. View "Newland v. Commissioner of Correction" on Justia Law

In this negligence case, the Supreme Court answered a question certified to it by a federal district court by concluding that the trial evidence was not legally sufficient to support the jury's finding that a continuing course of conduct tolled the statute of limitations.Plaintiff insurer brought this untimely filed action against Defendant claims adjuster alleging that Defendant caused Plaintiff to incur liability to a mortgagee. Plaintiff argued that the limitation period for commencing an action was tolled until Defendant produced a document in its files that reflected the mortgagee's interest during the course of litigation between the mortgagee and Plaintiff. The jury rendered a verdict in favor of Plaintiff. The court, however, set aside the jury's verdict on the ground that there was insufficient evidence to support the jury's finding that a continuing course of conduct tolled the action. The Supreme Court concluded that the evidence was not legally sufficient to toll the statute of limitations. View "Essex Insurance Co. v. William Kramer & Associates, LLC" on Justia Law

The Supreme Court held that, in light of Patsy v. Board of Regents, 457 U.S. 496, 501 (1982), and its progeny, a plaintiff is not required to exhaust administrative remedies prior to filing a 42 U.S.C. 1983 claim in state court, regardless of the type of relief sought, and therefore, this Court's holdings in Pet v. Department of Health Services, 542 A.2d 672 (1988), and Laurel Park, Inc. v. Pac, 485 A.2d 1272 (1984), that exhaustion of state administrative remedies is a jurisdictional prerequisite to the filing of a section 1983 action for injunctive relief are overruled.Plaintiff, a homeowner who was the subject of several enforcement action under a municipal blight ordinance, brought a claim alleging a deprivation of civil rights under 42 U.S.C. 1983. The trial court dismissed Plaintiff's section 1983 claims for lack of subject matter jurisdiction on the ground that Plaintiff had failed to exhaust his administrative remedies. The Appellate Court affirmed. The Supreme Court reversed with respect to Plaintiff's section 1983 claims, holding that Plaintiff was not required to exhaust his state administrative remedies prior to filing his section 1983 claims in state court. View "Mangiafico v. Farmington" on Justia Law

In these public interest appeals arising from a mix-up at a high school polling place in the town of Stratford where approximately seventy-six voters received the incorrect ballots, rendering those voters unable to cast a vote for their assembly district's state representative, the Supreme Court affirmed the judgment of the trial court insofar as it dismissed Plaintiff's complaint and reversed the trial court's judgment with respect to its issuance of a temporary injunction, holding that the trial court lacked jurisdiction over Plaintiff's claims and similarly lacked jurisdiction to issue a temporary injunction.Plaintiff, a Republic Party's candidate for state representative, brought this action seeking declaratory relief, a new election, and injunction prohibiting certain state defendants from declaring the intervening defendant, the Democratic Party's candidate, as the winner of that election. The trial court dismissed the complaint in part as barred by the elections clause set forth in Conn. Const. art. III, 7 but granted Plaintiff's application for a temporary injunction. The Supreme Court reversed in part, holding (1) the elections clause gives the state House of Representatives exclusive jurisdiction over this election contest; and (2) the trial court lacked jurisdiction to enjoin the state defendants from canvassing the votes and declaring a winner, even temporarily. View "Feehan v. Marcone" on Justia Law

The Supreme Court reversed the appellate court's decision affirming the trial court's judgment dismissing Plaintiff's appeal from the decree of the probate court monitoring use of a September 11th Victim Compensation Fund award that had been paid to Plaintiff, the surviving spouse, as a "representative payee" for the benefit of her minor child, holding that the probate court lacked jurisdiction over the fund award.Plaintiff's husband died in the September 11, 2001 terrorist attack on the World Trade Center and died intestate. Plaintiff filed a claim for compensation from the fund. Plaintiff was awarded $1,153,381, and the couple's minor child was awarded $1,271,940, which Plaintiff was to be paid on behalf of the minor child. The probate court appointed a guardian ad litem for the minor child in the estate administration proceedings and directed that the minor child's share of the benefits from the fund be placed into a guardianship account. Plaintiff unsuccessfully moved to dismiss the guardianship proceedings for lack of jurisdiction, and the trial court dismissed Plaintiff's probate appeal. The Supreme Court reversed, holding that the probate court lacked jurisdiction over the fund award paid to Plaintiff as a representative payee because that award was neither the property of the decedent's estate nor the property of the minor child. View "Hynes v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court in this interlocutory appeal regarding what preclusive effective to give in this action to the findings and judgment rendered by an English court in a prior action brought by Plaintiff against the named defendant, holding that the Appellate Court correctly found that none of the parties was entitled to the claimed preclusive effect.The English action resulted in a $243,023,089 judgment, plus interest, against the named defendant, Sebastian Holdings, Inc. Plaintiff, Deutsche Bank AG, later commenced the instant action against Sebastian and Alexander Vik, the sole shareholder and sole director of Sebastian. Plaintiff sought to pierce Sebastian's corporate veil and hold Vik personally liable for his corporation's judgment debt. All parties claimed, unsuccessfully, an entitlement to a preclusive effect as a result of the final judgment rendered in the prior English action. The Appellate Court agreed with the trial court that the parties were not entitled to have this action decided in their respective favor on the basis of the alleged preclusive effect of the English judgment. The Supreme Court adopted the Appellate Court's opinion as the proper statement of the issues and the applicable law concerning those issues and affirmed. View "Deutsche Bank AG v. Sebastian Holdings, Inc." on Justia Law